Legal · Controlled draft
Data Retention Policy
Draft retention, export, deletion, and residual-copy decision framework.
1. Retention Principles
OperelliOS should retain data only for approved service, security, support, contractual, and legal purposes.
Retention periods must be defined by category and system rather than by a single platform-wide number. A public promise must match executable deletion, export, backup, and legal-hold behavior.
This draft intentionally leaves periods unresolved until product, engineering, legal, and finance approve them.
2. Retention Decision Matrix
Each row requires a documented owner, system inventory, deletion method, exception logic, and verification test.
| Data category | Active account | After termination | Required decision |
|---|---|---|---|
| Tenant operational records | Retained while needed to provide the Service | [PRODUCT/LEGAL DECISION REQUIRED] | Export window, deletion trigger, supported formats, legal exceptions |
| Account and identity records | Retained while account or security need exists | [LEGAL/ENGINEERING DECISION REQUIRED] | Recovery, fraud prevention, audit and deletion behavior |
| Support records | [PRODUCT DECISION REQUIRED] | [LEGAL DECISION REQUIRED] | Ticket retention, attachments, quality review and deletion requests |
| Audit and mutation records | Retained for integrity and accountability | [LEGAL/ENGINEERING DECISION REQUIRED] | Minimum period, access controls, immutability and legal holds |
| Security and operational logs | [ENGINEERING DECISION REQUIRED] | [ENGINEERING/LEGAL DECISION REQUIRED] | Detection value, cost, privacy impact and incident needs |
| Backups | [ENGINEERING DECISION REQUIRED] | Residual until approved purge cycle | Scope, frequency, restoration, encryption and maximum residual period |
| AI prompts, source content and outputs | [PRODUCT/ENGINEERING DECISION REQUIRED] | [PRODUCT/LEGAL DECISION REQUIRED] | Provider retention, trace needs, feedback, redaction and deletion propagation |
| Request-access or marketing records | Current preview form should not submit or store information | [PRODUCT/LEGAL DECISION REQUIRED if connected] | Consent, source, suppression and deletion |
| Financial or tax records | Not applicable to current public payment-processing MVP | Future Gate 1 decision | Applicable retention duties and system of record |
3. Active Accounts
During an active relationship, Customer Data may be retained as necessary to provide workflows, maintain integrity, support users, secure the Service, and comply with law.
The Customer should be able to correct or remove ordinary records through documented workflows where removal does not break legal, audit, relational, or financial integrity.
[ENGINEERING VERIFICATION REQUIRED: Inventory deletion and archival behavior for each bounded context.]
4. Termination and Export
The final model should provide a clear opportunity to obtain Customer Data after termination without creating indefinite access or hidden lock-in.
Recommended direction: a defined post-termination export window, usable structured formats where reasonably available, and clear support responsibility.
[PRODUCT DECISION REQUIRED: Approve export window, format, self-service versus support-assisted process, fees if any, and treatment of suspended or disputed accounts.]
[ENGINEERING VERIFICATION REQUIRED: Confirm export coverage, tenant scoping, authorization, idempotency, large-export handling, audit events, and secure delivery.]
5. Deletion
After the approved retention and export periods, Customer Data should be deleted or rendered inaccessible from active systems, subject to legal holds, security needs, financial-record obligations, dispute preservation, and residual backups.
Deletion requests must be authenticated, authorized, tenant-scoped, auditable, and safe from accidental cross-tenant impact.
[ENGINEERING VERIFICATION REQUIRED: Confirm deletion workflow, cascading effects, tombstones, audit events, backup propagation, and recovery constraints.]
6. Backups and Residual Copies
Backups may retain residual copies after deletion from active systems until the applicable backup expires or is overwritten under the approved schedule.
Residual backup data should remain protected, unavailable for ordinary business use, and deleted through the normal backup lifecycle unless restoration is required.
[ENGINEERING VERIFICATION REQUIRED: Confirm actual backup architecture and maximum residual period.]
7. Legal Holds and Required Records
OperelliOS may retain records when reasonably necessary to comply with law, respond to valid legal process, resolve disputes, prevent fraud, enforce agreements, or establish and defend legal claims.
Legal holds should be authorized, documented, limited, access-controlled, reviewed, and released when no longer required.
[LEGAL REVIEW REQUIRED: Approve hold authority, notices, and jurisdiction-specific obligations.]
8. Aggregated and De-Identified Information
Properly de-identified or aggregated information may be retained separately from identifiable Customer Data only under the approved policy and controls.
OperelliOS should not preserve identifiable information merely by labeling it aggregated. Re-identification must be prohibited and technically constrained.
9. Policy Changes
Material changes to retention or deletion commitments should receive appropriate notice and must not be published before the corresponding systems and procedures are verified.
10. Questions
Retention, export, and deletion questions: [LEGAL REVIEW REQUIRED: Confirm legal and privacy contact email]
Related documents:
**Contact placeholder:** [LEGAL REVIEW REQUIRED: Confirm legal and privacy contact email]
Questions
Questions about retention, export, or deletion.
[LEGAL REVIEW REQUIRED: Confirm legal and privacy contact email]